Memorandum Findings of Fact and Opinion
SMITH, Judge:
This proceeding involves deficiencies in income tax for 1937, 1939, and 1940 in the respective amounts of $783.93, $24,508.46, and $286.49.
The questions for our determination are (1) whether petitioner is taxable in 1937 and 1939 on income which he claims to have received as guardian for his two sons; (2) whether petitioner is taxable, in 1937, 1939, and 1940, on the income from properties which...
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